{"operation":"document","citation":"CPF 320115003W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-04-14","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.432(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320115003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320115003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320115003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320115003W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.432(d). The case was opened on 2011-04-14 and is reported as closed as of 2011-04-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320115003W_Warning Letter_04142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320115003W/320115003W_Warning%20Letter_04142011.pdf\n\n320115003W_Warning Letter_04142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320115003W/320115003W_Warning%20Letter_04142011_text.pdf\n\n320115003W_Warning Letter_04142011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 14, 2011\nMr. Michael Pearson\nVP of Technical Services\nMagellan Pipeline Company LP\nOne Williams Center, Mail Drop 27\nTulsa, OK 74172\nCPF 3-2011-5003W\nDear Mr. Pearson:\nOn May 10-14, June 7-10, and December 14-17, 2010, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your records and facilities in Wisconsin, Iowa, and Illinois.\nAdditionally, records were reviewed at your Tulsa headquarters office.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. §195.404 Maps and Records.\n(c) Each operator shall maintain the following records for the periods specified;\n\n\n\n(3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is performed,\nwhichever is longer.\nMagellan personnel (Magellan) did not document the inspections of three control valves\nat the Iowa City station and terminals. Reviewing the records for their over-pressure\nprotection revealed that the company was not keeping records of their inspections of the\ncontrol valves. Magellan indicated that the control valves were inspected on an annual\nbasis, but they were not documenting those inspections. The work order program was\nmodified to ensure that proper documentation would be completed for future inspections.\n2. §195.432 Breakout tanks.\n(d) The intervals of inspection specified by documents referenced in paragraphs (b)\nand (c) of this section begin on May 3, 1999, or on the operator's last recorded date\nof the inspection, whichever is earlier.\n§195.432 (b) requires that each operator must inspect the breakout tanks according\nto API Standard 653. API 653 indicates that all tanks shall be given a visual\nexternal inspection by an authorized inspector. This inspection shall be called the\nexternal inspection and must be conducted at least every 5 years or RCN/4N years\n(where RCA is the difference between the measured shell thickness and the\nminimum required thickness in mils, and N is the shell corrosion rate in mils per\nyear) whichever is less. Tanks may be in operation during this inspection.\nMagellan personnel did not conduct the external inspection at the interval prescribed in\nAPI 653 (incorporated by reference). Review of the breakout tank records for this facility\nfound that breakout tanks at the Mason City station exceeded the maximum five year\ninspection interval following the July 2004 external inspection. The latest inspection\nfound that no repairs were needed on any of the tanks.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item(s)\n2\n\n\n\nidentified in this letter. Failure to do so will result in Magellan Pipeline Company LP being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2011-5003W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":4814}